Taxation of other income: residence-based taxation subject to permanent establishment or fixed base connections. Article 22 provides that items of income of a resident not covered elsewhere are generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or with independent personal services from a fixed base in the other State, in which case Article 7 or Article 14 applies; additionally, such other income arising in the other State may also be taxed there.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of other income: residence-based taxation subject to permanent establishment or fixed base connections.
Article 22 provides that items of income of a resident not covered elsewhere are generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or with independent personal services from a fixed base in the other State, in which case Article 7 or Article 14 applies; additionally, such other income arising in the other State may also be taxed there.
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